Using the International Traffic in Arms Regulation for Export Compliance
International Traffic In Arms Regulation Several years ago while serving as a defense contractor’s export compliance officer, I was approached by a business development manager. She stated that the company was pursuing a contract with a foreign country to provide a defense material. The material had both military and civilian application. In this case, they were pursuing a contract for the material with a civil application. She rationalized that since the transaction would not be a defense article, the company should not need to seek an export license. Though there is guidance for what and how to export, many exports issues are unique and may not be fully understood by defense contractors. As examples, recently a company was fined for violating an export law by shipping a controlled chemical. In another case, a company was charged with providing technical drawings to a foreign country. A few years ago, Chinese officials downloaded technical information from an American defense c...